Six individuals were indicted by a federal grand jury in Kansas City for their involvement in a conspiracy to use a drone to smuggle contraband into a federal prison in Kansas.

Key Indictment Details

Charged with a single count of conspiracy to possess and provide contraband in prison are Dale Gaver III (35 years old), Dale Gaver II (54 years old), Joshua Hamilton (37 years old), and Rex Hill (33 years old), all residents of Omaha, Nebraska. In addition, Melvin Edwards (44 years old) and Tamarae Hollman (36 years old) from Riverside, California, face charges of conspiracy to possess and provide contraband in prison.

As per court records, Melvin Edwards, Dale Gaver II, Dale Gaver III, Joshua Hamilton, Rex Hill, and Tamarae Hollman are alleged to have conspired between August 2020 and May 2021 to transport illicit items, including cell phones, synthetic cannabinoid K2, marijuana, and tobacco, into Leavenworth Penitentiary. They allegedly used a drone to drop the contraband into the prison yard.

Furthermore, in addition to the conspiracy charge, Hill faces a separate count of attempting to supply contraband in prison. Similarly, Gaver III, who was an inmate at Leavenworth Penitentiary during the period of the alleged conspiracy, is charged with attempted possession of prison contraband and possession of prison contraband.

The indictment alleges that Gaver III and Edwards were inmates at the United States Penitentiary (USP) Leavenworth. Edwards and Gaver III coordinated the introduction of contraband into USP Leavenworth with the help of Hill, Gaver II, Hamilton, Hollman, and other unindicted co-conspirators.

Splash Drone 3 Plus

The indictment states that Gaver II helped acquire the drone used to introduce contraband into USP Leavenworth, and Hollman purchased the drone and replacement parts, a Splash Drone 3 Plus with PL4 Night Camera, online for $2,509 in August 2020. In December 2020, Hollman purchased a replacement video antenna and a PL4 Payload Release System with Low Light Vision Camera for a Splash Drone 3 Plus.

PL4 HS - Night Camera Spotlights and Payload Release for Splashdrone 3+
SplashDrone 3+ (Image Credit:


According to online resources, the “…PL4 features a color night vision camera coupled with a remotely controlled payload release. With excellent low-light sensitivity as well as built-in spotlights, the PL4 enables flights in low light and darkness- recording startling, detailed, color images even at night.”

The resource further states, “The PL4 release mechanism is made of high-quality stainless steel and machined aluminum. The precision mechanism is fast to set up and allows for accurate deployment of payloads up to 1kg- wherever you need.”

Photograph of the PL4 release mechanism
PL4 night vision camera coupled with a remotely controlled payload release (Image Credit:


The Federal Bureau of Investigation (FBI) is investigating the case.

An indictment is merely an allegation, and all defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.

View other criminal, civil, and investigative documents on C-UAS Hub., including similar schemes for using drones to smuggle contraband into prisons.

(Press Release)

See the Federal Grand Jury Indictment document.